Re: H3 Shipment

["Alan R. Marchand" <radarm@accessnv.com>]

Instruments and Articles are the first two Columns. Material package limits is
for Limited Quantities. Note the name for Table 7: " Activity Limits for
Limited Quantities, Instruments and Articles. If Table 7 is not for Excepted
package-Limited Quantity of Material then where do you find the limits for
Limited Quantity?

At 04:48 AM 7/7/98 -0500, you wrote:
>At 10:55 AM 7/6/1998 -0500, you wrote:
>>Tom,
>>      With the details you have provided I can suggest that the
>>situation is
>>as follows. 9 curies of H3 in the situation you describe
>>qualifies as a
>>limited Quantity 49 CFR 173.421( 2.0X10-2 A2).
>>As such the only packaging requirements would be a
>>package that meets
>>the general design criteria specified in 173.410.
>>      Assuming all the dose rate and contamination criteria
>>are met as well
>>as any applicable requirements from 173.421, I would say
>>that you do
>>NOT have a violation. HOWEVER, if you had , the problem is
>>who to tell.
>>In a situation such as this, our first approach would be to
>>notify the
>>shipper and then D.O.T ( they don't provide any specific
>>contact point, but
>>it is THEIR regulation being violated.) If the avenue is
>>available to you a
>>courtesy notification top the NRC or state licensing body
>>would be
>>appropriate. ( You might want to check any state regs which
>>could apply)
>>I hope this helps..... I have been there before and it's pretty
>>frustrating....If
>>you have any further questions I'm at   j.lepere@nypa.gov
>>Good Luck,
>> John LePere
>> Waste Management General Supervisor
>> New York Power Authority
>> Indian Point #3 NPP (914) 736 8470 
>>
>John,
>
>I appreciate your response.  The problem I have with the values listed in
>table 7, is that they are for instruments and articles.  The definition for
>instrument and articles clearly states the the radioactivity is a component
>part of the instrument or article.  I do not beleive that a vacuum pump
>contaminated with 9 Ci of H3 meets this definition.  
>